ML23010A088

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– Summary of Regulatory Audit in Support of License Amendment Request to Revise Control Rod Technical Specifications
ML23010A088
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 01/15/2023
From: Audrey Klett
Plant Licensing Branch 1
To: David Jones
Susquehanna
Klett A
References
EPID L-2023-LLA-0003
Download: ML23010A088 (1)


Text

January 15, 2023 Mr. Derek Jones Acting Site Vice President Susquehanna Nuclear, LLC 769 Salem Boulevard NUCSB3 Berwick, PA 18603-0467

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNIT 2 -

SUMMARY

OF REGULATORY AUDIT IN SUPPORT OF LICENSE AMENDMENT REQUEST TO REVISE CERTAIN CONTROL ROD TECHNICAL SPECIFICATIONS (EPID L-2023-LLA-0003)

Dear Mr. Jones:

By letter PLA-8042 dated January 10, 2023 (Agencywide Documents Access and Management System Accession No. ML23010A265), as supplemented by letter PLA-8048 dated January 14, 2023 (ML23014A002), Susquehanna Nuclear, LLC (the licensee) submitted a license amendment request (LAR) for Susquehanna Steam Electric Station, Unit 2.1 The licensee requested to revise certain technical specifications for the control rods.

The U.S. Nuclear Regulatory Commission (NRC) staff conducted a virtual audit to support its review of the LAR. The NRC staff audited various licensee documents and interviewed licensee staff. The NRC staff issued its audit plan on January 11, 2023 (ML23010A087).

of this audit summary lists the individuals that participated in the audit. Enclosure 2 lists the NRC staffs audit questions and documents the NRC audit activities.

The NRC staff conducted the audit using virtual meetings and an internet-based portal provided by the licensee. Using the licensees portal, the NRC staff reviewed documents (e.g., calculations and reports) related to the LAR but not available on the Susquehanna dockets. During the audit, the staff also met virtually with the licensee on January 12 and 13, 2023. The staff used these meetings to confirm its understanding of the LAR, discuss the documents in the portal, and decide whether any information needed to be submitted on the docket to complete the NRC staffs safety evaluation.

During the audit, the staff identified information it needed on the docket to support its review.

After the audit discussions, the NRC sent the licensee a request for additional information on January 13, 2023 (ML23013A208). The licensee responded to this request on January 14, 2023 (ML23014A002). The NRCs licensing project manager informed licensee staff by email on January 15, 2023, that the NRC staff had completed its audit. There were no open items resulting from the audit.

1 Renewed Facility Operating License No. NPF-22

If you have any questions, please contact me at (301) 415-0489 or by email to Audrey.Klett@nrc.gov.

Sincerely,

/RA/

Audrey L. Klett, Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-388

Enclosures:

1. List of Audit Participants
2. List of Audit Questions and Audited Documents cc: Listserv

ML23010A088 ADAMS Package Accession No. ML23010A090 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/SNSB/BC (A)

NAME AKlett KEntz DWoodyatt DATE 01/14/2023 1/14/2023 01/14/2023 OFFICE NRR/DEX/EICB/BC NRR/DSS/STSB/BC NRR/DORL/LPL1/BC NAME MWaters (RStattel for)

VCusumano HGonzález DATE 01/14/2023 01/14/2023 01/14/2023 OFFICE NRR/DORL/LPL1/PM NAME AKlett DATE 01/15/2023

List of Audit Participants U.S. Nuclear Regulatory Commission Staff Ashcraft, Joseph (NRR1/DEX2/EICB3)

Bresson, Justin (R14/DORS5)

Elliott, Robert (NRR/DSS6/STSB7)

González, Hipo (NRR/DORL8/LPL19)

Grover, Ravi (NRR/DSS/STSB)

Heisserer, Jamie (NRR/DORL)

Hardgrove, Matthew (R1/DORS)

Klett, Audrey (NRR/DORL/LPL1)

Miller, Ed (NRR/DORL/LPLII-110)

Peabody, Charles (NRR/DSS/SNSB11)

Stattel, Richard (NRR/DEX/EICB)

Woodyatt, Diana (NRR/DSS/SNSB)

Licensee12 Staff Brisson, Ian Brown, Katie Hartzell, Jason Hirt, Jeff Hoppe, Dave Krick, Melissa Royko, Catie Smith, Derek 1 Office of Nuclear Reactor Regulation 2 Division of Engineering and External Hazards 3 Instrumentation and Controls Branch 4 Region I Office 5 Division of Operating Reactor Safety 6 Division of Safety Systems 7 Technical Specifications Branch 8 Division of Operating Reactor Licensing 9 Plant Licensing Branch 1 10 Plant Licensing Branch II-1 11 Nuclear Systems Performance Branch 12 Susquehanna Nuclear, LLC

List of Audit Questions and Documents Reviewed The U.S. Nuclear Regulatory Commission (NRC) staff requested the following information during its audit to support its review of the license amendment request (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23010A265) for the Susquehanna Steam Electric Station (Susquehanna), Unit 2.

ITEM No.

AUDIT REQUEST 1

Technical specification (TS) bases for TS 3.1.3, 3.1.6, and 3.3.2.1 2

Discussion of whether the analyzed rod position withdrawal and insertion sequences were developed per the existing control rod drop accident methodology and, if yes, where the methodology addresses the analyzed rod position sequence.

3 Discussion of whether the rod worth minimizer will be reprogrammed from the banked position withdrawal sequence to the analyzed rod position sequence, or whether it will be controlled administratively per TS 3.3.2.1, Required Action C.2.2.

4 Discussion of the actual sequence changes and how the licensee will effectively manage the anticipated control rod friction issues during the restart and power ascension rod manipulations.

5 Discussion of whether the inoperable rods along the periphery be withdrawn from the core.

6 Discuss how the instrumentation will be used by operators to accommodate the analyzed rod position sequences and whether the operators would use existing bypass features or if the rod worth minimizer and/or rod sequence control systems setpoints would be changed to allow the different rod sequences.

7 The staff is reviewing whether the control rod drop accident (CRDA) results discussed in the updated final safety analysis report (UFSAR) remain limiting. Does the rod sequence change affect UFSAR Table 15D.4.9-2 (e.g., if a different rod location becomes most limiting as the CRDA)? If yes, please describe the changes.

8 TS 3.10.7, Control Rod Testing -Operating, and TS 3.10.8, SHUTDOWN MARGIN (SDM) Test - Refueling, concern banked position withdrawal sequence requirements. Please explain why these TS are not affected by the proposed change of the use of the analyzed rod position sequence method.

9 Presentation on the amendment request.

10 Provide copy of NEDO-21231, Banked Position Withdrawal Sequence, dated January 1977.

11 Provide core map layout of pull sequence similar to NEDO-21231, Figures 3-1 and 3-2, and discuss efforts to manage radial symmetry.

12 Discuss and provide insights about the changes in CRDA rod worth based on the radial peaking effects anticipated from delayed withdrawal of the peripheral rods.

These radial peaking effects are described on page 4-9 of NEDO-21231.

The NRC staff reviewed, in a sampling manner, the following licensee documents during its audit (this list does not include documents available in ADAMS):

Presentation titled, 2023 NRC Control Cell friction Overview, dated January 12, 2023 Drawing of representative analyzed rod position sequence startup groups analogous to Figures 3-1 and 3-2 of NEDO-21231 Framatome ANP-4037, Revision 0, Susquehanna Unit 2 Cycle 21 Analyzed Startup Sequences for CRDA and EOFP and EOC, January 2023 In reviewing the documents, the NRC staff was able to observe how the licensees evaluations used the existing approved AURORA-B CRDA analysis methodology and how the evaluation results were measured against the existing acceptance criteria in the UFSAR Chapter 15.4.9.